The GE Capital case shone a spotlight on whether and how “implicit support” should be allowed for in the analysis of intra-group debt. This article explores implicit support in greater detail and begins to outline a transfer pricing framework for dealing with this issue.
Significant tax risk to non-US companies created by America First Trade Policy
On his first day in office, President Trump signed two memoranda, the Global Tax Deal and the America First Trade Policy, covering noteworthy international...